On February 10, 2025, President Trump signed Proclamation 10896, Adjusting Imports of Steel into the United States, imposing 25% tariffs on all steel imports and Proclamation 10895, Adjusting Imports of Aluminum into the United States (collectively the “Proclamation(s)”) increasing tariffs for aluminum products and certain steel and aluminum derivative products from 10% to 25% effective at 12:01 am eastern daylight time on March 12, 2025. On March 10, 2025, Customs & Border Protection (“CBP”) issued the instructions for the implementation of the steel tariffs] and the aluminum tariff , including derivative products, as well as the user-friendly Section 232 Chart.

The Proclamations expand the list of derivative products contained in the current Section 232 tariffs — initiated under the first Trump Administration and continued during the Biden Administration — and now includes both derivative and downstream products. The Proclamation Annexes include the list of HTSUS classifications currently targeted for the implementation of the tariffs (Steel product HTS Annex: 90 FR 9817 and Aluminum product HTS Annex 90 FR 9807). The Proclamations direct Commerce to establish, within 90 days, a process for expanding the list of products included in the derivative product list and to create a mechanism for U.S. producers and industry associations to request further additions. Importantly, no exemption procedures are addressed.

The Proclamations remove all prior General Approved Exclusions (GAE) effective March 12, 2025, and confirms the current expiration date of all active Section 232 (or an earlier date upon reaching the respective quantity limitation, whichever occurs first). No new Section 232 exclusions will be accepted and all pending exclusions will not be reviewed. All country specific exemptions¹ and quotas allocated to certain countries² will be revoked effective March 12, 2025.

Modifications to the HTSUS for Implementation of the Proclamation Steel and Aluminum Tariffs:

The Proclamations instruct the U.S. International Trade Commission, in consultation with the Department of Commerce, U.S. Customs and Border Protection (“CBP”) and other relevant executive departments and agencies, to revise the Harmonized Tariff Schedule of the United States (HTSUS/HTS) to conform to the amendments and effective dates directed in the Proclamations.

Modifications to the HTSUS were published in the Federal Register on March 5, 2025, for implementation for most of the Proclamation Tariffs to begin March 12, 2025. All classifications of steel and aluminum products previously subject to the Section 232 duties will remain in effect along with the previously identified derivative products and new derivative products classified in Chapters 73 (steel) and Chapter 76 (aluminum). The new derivative and downstream steel products included in Chapters 84, 85 and 94³ will be announced at a later date, becoming effective upon public notification by the Secretary of Commerce.

The new aluminum derivative and downstream products included in Chapters 66, 83, 84, 85, 87, 88, 90, 94, 95 and 96,⁴ will be announced for implementation in the same manner but have already been assigned subdivision Chapter 99 identifications in the current instructions. Once announced by the Commerce Secretary, the derivative and downstream steel and aluminum products will be assessed Section 232 duties based on the steel and aluminum content only. The steel and aluminum content must be provided in kilograms and the unit of measure as specified in the product HTS.

Steel.

Aluminum.

Because these changes are ongoing, we will continue to disseminate updated Alerts periodically for our clients on the relevant changes. For guidance tailored to your business needs, please contact Dentons Cohen & Grigsby’s International Trade team. 

Dentons Cohen & Grigsby will continue to monitor these developments and provide additional updates. We provide our clients access to resources in Canada, Mexico, China, and globally to help navigate these rapidly changing trade measures.

Addendum March 12, 2025 - UPDATED GUIDANCE: Import Duties on Imports of Aluminum, Steel and Aluminum and Steel Derivative Products

On March 11, 2025, the DCG Trade Team issued an Alert titled “Department of Commerce Announces Implementation Instructions for March 12, 2025, Steel and Aluminum Additional Section 232 Tariffs (“March 12 Alert”).  This Addendum to the March 12 Alert announces an increase in the scope of products subject to the additional 25% Section 232 Tariffs. 

On March 12, 2025, Customs & Border Protection (“CBP”) issued CSMS #64384496 (aluminum) and CSMS #64384423 (steel) announcing that, effective 12:01 a.m. Eastern Daylight Time on March 12, 2025, the Secretary of Commerce has certified the collection of a 25 percent import duty on certain additional aluminum and steel derivative articles based on specific identified HTS classifications outside of Chapters 73 (Steel) and 76 (aluminum) listed in CSMS #64384496 (aluminum) and CSMS #64384423 (steel).  These technical CBP Messages provide guidance on how to enter products subject to the additional Section 232 tariffs. 

If you have questions as to whether your product may be subject to these additional Section 232 duties, please contact the DCG Trade Team.

1. Canada, Mexico, Australia, Ukraine↩
2. Argentina, Brazil, South Korea, European Union, United Kingdom, Japan↩
3. New Steel derivative and downstream products: Subdivision (n) HTS 9903.81.91↩
4. New Aluminum derivative and downstream products: Subsection (k) HTS 9903.85.08↩